A&P MECH IS INFORMED WELL AFTER THE FACT THAT THE FAA MAY VIOLATE HIM FOR A DEFERRED MAINT ITEM THAT FAA FEELS SHOULD HAVE BEEN AN MEL ITEM.

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TODAY; MAY/XX/96; I WAS INFORMED BY OUR AIRLINE'S LCL FAA AVIONICS INSPECTOR THAT HE MAY BE FILING A VIOLATION AGAINST ME. DURING A ROUTINE RECORDS INSPECTION THIS INSPECTOR FOUND AN ACFT LOG BOOK PAGE; A B727-100 FREIGHTER; ON WHICH I HAD RECORDED A DEFERRED MAINT ITEM USING OUR COMPANY GENERAL MAINT MANUAL AS A REFERENCE RATHER THAN THE MEL. THIS ITEM SPECIFICALLY WAS A STUCK EXPANDED LOC FAIL FLAG LOCATED ON THE ATTITUDE DIRECTOR INDICATOR; ADI. DURING MY EXAMINATION OF THIS PROB I PROVED THAT THE FAULT CAUSING THIS FLAG TO STICK WAS LOCATED IN A COMPONENT BTWN THE NAV RECEIVER AND THE COCKPIT INDICATOR. THERE WAS NO MALFUNCTION OF THE VHF NAV SYS ITSELF; IN ADDITION THE FLT DIRECTOR SYS WAS UNAFFECTED. IT HAS BEEN COMPANY POLICY AT THIS AIRLINE THAT WHEN A DISCREPANCY IS NOT A SAFETY OF FLT ISSUE AND THAT THE MEL DOES NOT COVER THE MALFUNCTION IN QUESTION THAT THE GENERAL MAINT MANUAL CAN BE USED AS A REFERENCE FOR THAT DEFERRED MAINT ITEM. ON THIS OCCASION I FOLLOWED THE COMPANY PROCS AND DEMONSTRATED THE FAULT TO THE SHIFT SUPVR WHO AGREED IT WAS NOT A FLT SAFETY ISSUE AND THAT THE MEL DID NOT COVER THIS DISCREPANCY. I THEN IN TURN RECEIVED APPROVAL OF THE GENERAL MAINT MANUAL REFERENCE FOR THE DEFERRED MAINT ITEM FROM THE SHIFT MGR. THE CREW THAT WAS TO OPERATE THE ACFT WAS BRIEFED ON THE STATUS OF THIS INDICATOR AND VOICED NO CONCERNS OVER OPERATING THE ACFT WITH THIS DEFERRED MAINT ITEM IN EFFECT. THE ACFT OPERATED FOR ONE FLT WITH THIS DEFERRED MAINT ITEM IN EFFECT. THE MALFUNCTIONING PIECE OF EQUIP WAS REPLACED IN DUE COURSE AND THE PROB HAS NOT REOCCURRED. SINCE MY USE OF THE GENERAL MAINT MANUAL FOR THIS DEFERRED MAINT ITEM I CAN SHOW TWO OTHER OCCASIONS THAT THIS REFERENCE HAS BEEN USED IN A SIMILAR MANNER BY THIS AIRLINE. I BELIEVE THE REASON DEFERRED MAINT ITEMS OF THIS NATURE ORIGINATE IS BECAUSE THE MEL THAT THIS AIRLINE USES IS SO GENERAL IN CONTENT THAT ENTIRE SYS MUST BE RENDERED INOP SIMPLY BECAUSE A SUBFUNCTION OF THE SYS MAY BE MALFUNCTIONING. FOR EXAMPLE IF THE GS RECEIVER IS NOT WORKING THE ENTIRE VHF NAV SYS MUST BE DECLARED UNUSABLE COVERING THE VOR; LOC; AND GS; EVEN THOUGH ONLY THE GS IS ACTUALLY DEFECTIVE. TO RESOLVE THESE CONFLICTS I BELIEVE MAINT PERSONNEL NEED TO BE BRIEFED SPECIFICALLY ON THE LIMITATIONS OF GMM DEFERRALS; OR THE MEL NEEDS TO BE APPROPRIATELY REVISED TO ALLOW FLEXIBILITY WITHIN MULTIFUNCTION SYS.